CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB-657), which is aimed at eliminating slavery and human trafficking from product supply chains, went into effect in California. The act requires retail and manufacturing companies to disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.

In accordance with the California Transparency in Supply Chains Act of 2010 (SB-657), Rodan & Fields, LLC, Rodan & Fields Canada, ULC and its affiliates (together "Rodan + Fields") is committed to a work environment that is free from human trafficking and forced labor. Rodan + Fields is committed to conducting business in a legal, ethical and responsible manner. To formalize the same expectations of our suppliers, in 2016, Rodan + Fields is developing a Supplier Code of Conduct that will address all ethical and environmental considerations relating to supply chain transparency.

To address the requirements of the California Transparency in Supply Chains Act, Rodan + Fields has made the following efforts:

Verification. Rodan + Fields requires direct material suppliers to comply with all laws and to not engage in the employment of child, forced, indentured, involuntary, prison or uncompensated labor.

Audits. Rodan + Fields does not currently conduct compliance audits of our suppliers to evaluate compliance with Rodan + Fields’ standards for trafficking and slavery in supply chains. However, we will consider measures such as audits or third party verification for any suppliers we determine to be in violation.

Certification. Rodan + Fields currently does not require direct material suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Accountability. Rodan + Fields maintains internal accountability standards and procedures, including procedures for reporting violations, as well as confidentiality and whistleblower protections, for employees or contractors failing to meet company standards regarding slavery and trafficking.

Training. Rodan + Fields provides training to ensure that its employees with direct responsibility for product supplier management are knowledgeable and aware of the issues and concerns surrounding the supply chain, including mitigating the risk of human trafficking and slavery.